SMS Gap Review
A plain-English review of your current SMS against the post-1 June 2025 Marine Order 504 requirements, highlighting what is working, what is missing and what needs to change.
What Marine Order 504 Now Requires
Practical SMS obligations for domestic commercial vessel operators
The Updated Framework
The revised Marine Order 504 requirements took effect on 1 June 2025. Since then, vessel owners have needed to ensure their Safety Management System clearly addresses the mandatory safety elements that apply to their vessel class and operation.
For Class 1, 2 and 3 vessels, AMSA now expects the SMS to cover these core elements:
- Fatigue management plan
- Drug and alcohol policy
- Operational and emergency procedures
- Master and designated person responsibility statement
- Stability risk assessment
- Record of vessel modifications
- Assembly station arrangements
What This Means for Operators
For Class 4 vessels, the SMS must still document drug and alcohol controls, emergency procedures, the designated person's responsibility statement, and a stability risk assessment. Even where a simplified SMS is available, AMSA still expects the system to be documented, understood and applied in practice.
Generic templates rarely reflect the vessel, crew, route, operating conditions and risk profile they are supposed to govern. That creates audit exposure and leaves operators with paperwork that does not match reality.
A compliant SMS needs to be clear, vessel-specific and usable by the people onboard and ashore. It should support day-to-day decision-making, not sit unused in a folder.
Brindabella Legal works with you to build or review an SMS that is practical, current and defensible under AMSA scrutiny.
How We Can Help
Tailored maritime safety support for owners and operators
SMS Design and Upgrade
We design new SMS frameworks or restructure existing ones so they are logical, operator-friendly and aligned with your vessel class, operations and risk profile.
Drafting Key Components
We draft the core elements AMSA expects, including fatigue plans, drug and alcohol policies, emergency procedures, stability risk assessments and responsibility statements.
Crew and Designated Person Briefings
Short, focused briefings help ensure the SMS is understood, implemented and maintained by the people who are responsible for using it in real operations.
Ongoing Review and Audit Readiness
We support periodic reviews, incident-driven updates and audit preparation so your SMS stays current as operations, vessels, crew or risk settings change.
Full SMS and Simplified SMS Support
Choosing the right compliance pathway for your vessel and operation
Full SMS Support
For many Class 1, 2 and 3 vessels, and for operators with more complex risks, a full SMS remains the right structure. We help build systems that cover the mandatory Marine Order 504 elements while staying practical for masters, crew and shore-based personnel.
That includes aligning procedures, records, risk controls and review processes so the SMS is not only technically compliant, but genuinely useful in daily operations and incident response.
Simplified SMS for Eligible Vessels
AMSA's simplified SMS pathway applies to eligible Class 2, 3 and 4 vessels. It reduces administrative burden for smaller, less complex operations, but it still requires an SMS that reflects the vessel and the way it actually operates.
If you are eligible, we can help you decide whether to move to a simplified SMS or keep a full SMS, then build the right framework around your real operating conditions.
A Clear Path to Compliance
Our approach is straightforward and practical:
- Review your current SMS, vessel class, operations and risk profile
- Identify the required Marine Order 504 elements and any compliance gaps
- Draft or refine the right documents, procedures and evidence controls
- Help embed the system with crew, checklists and accountability
That gives owners and operators a cleaner pathway to compliance, stronger assurance during audits, and a more useful safety system onboard.
If Your SMS Has Not Been Updated Since 1 June 2025
If your existing system still reflects the pre-1 June 2025 requirements, it should be reviewed now. Delaying that update increases the risk that your documented controls do not match current AMSA expectations or your actual operations.
Why Choose Brindabella Legal
Transport safety specialists who build systems that work in practice
Transport Safety Specialists
We work across regulated transport sectors including maritime, aviation, heavy vehicle and rail, so we understand how operational risk and regulatory scrutiny intersect.
Bespoke, Not Generic
We do not rely on off-the-shelf templates. Every SMS is built around your vessel class, crewing model, routes, operating environment and existing systems.
Operationally Grounded
Procedures, checklists and forms are written in clear, practical language so they can be used onboard and ashore, not filed away and ignored.
Defensible and Audit-Ready
Our work is designed to align with Marine Order 504, broader legal obligations and the evidence standards regulators expect to see if questions are asked.
End-to-End Support
From initial gap reviews to drafting, rollout, updates and audit readiness, we support the full lifecycle of maritime safety compliance.